The IRS released the final drafts of the Forms 1094-C, 1095-C, 1094-B and 1095-B, as well as Instructions for the C-forms and B-forms. These final editions reflect the previously issued drafts for the ACA 2018 calendar year reporting. As a reminder, applicable large employers (ALE) must send 1095-C’s to full-time employees with a copy to the IRS. ALE’s with self-insured health plans have the option of sending 1095-B’s to covered individuals who are not full-time employees, such as retirees or COBRA continuants. In addition, employers must submit a Form 1094-C and/or a 1094-B to the IRS, as applicable.
The 2018 forms are generally due to individuals by January 31, 2019 and to the IRS by February 28, 2019 (or March 31st if filing electronically). You should be preparing now for your upcoming reporting obligation and working with your reporting vendor to provide necessary information.
If you are uncertain whether you qualify as an ALE for the 2018 calendar year, i.e., had 50 or more employees in 2017 based on the IRS’ specific formula, please refer to their website for details, such as controlled group rules and which employees to include in your calculation.
Read our Reporting Guide bulletin (updated November 2017) for general information on the who, when, where, what and how of ACA reporting including potential penalties for late or incorrect filings. If you have questions or need help, please contact one of our employee benefits consultants.